Ken, replies below.
Regards, Keith Armstrong

In a message dated 06/01/02 06:56:46 GMT Standard Time, 
ken.ja...@emccompliance.com writes:

> Subj:Re: EMC-related safety issues
> Date:06/01/02 06:56:46 GMT Standard Time
> From:    ken.ja...@emccompliance.com (Ken Javor)
> To:    cherryclo...@aol.com, cortland.richm...@alcatel.com
> CC:    emc-p...@majordomo.ieee.org
> 
> What an EMC engineer who understands the physics of field-to-wire coupling 
> would say is that the operation of non-antenna connected electronics 
> associated with one subsystem will not be degraded by close proximity with 
> the non-antenna connected electronics of another subsystem.  Forget 10 
> meters.  Are the PCs in your office separated by 10 m?  Would you expect 
> two PCs stacked side-by-side or one on top of the other to interact in any 
> manner?  These are rhetorical questions.
> 

I don't see the relevance of this paragraph to my example. This might be 
because 
I am a little slow. I would appreciate more explanation.

> About the blood pressure monitor example.  Not enough info here to back out 
> what is wrong, but basic logic theory says when the conclusion is 
> impossible, you must re-examine your assumptions.  If 92 dBuV/m were enough 
> to make the device malfunction, it would malfunction a lot and there would 
> have been enough trouble reports to get it fixed or withdrawn. And 92 
> dBuV/m at 10 meters is SCREAMING!!!  I am on location and don't have FCC 
> regs easily available, but the limits stair-step around 40 dBuV/m at 3 m, 
> per my recollection.

This is exactly why I emphasised that the front-panel display of the blood 
sample incubator (not a blood pressure monitor) continued to read the 
set-point temperature (37.1C) even though the actual temperature could be way 
off. 
I am confident that in actual operation the incubator temperature was quite 
often at least a few degrees C different from what was displayed on its front 
panel, probably affecting the performance of the reagents.

And I don't think that 92dBuV/m is a high field strength to be emitted by a 
PC placed nearby, or for a non-compliant laptop at 10 metres.

> Would I feel comfortable placing a CISPR compliant PC next to a medical 
> device qualified to 1 V/m?  There is an inherent (not planned) margin of 
> safety here that is many orders of magnitude.   The answer is absolutely 
> yes.  If there were a problem, I would expect it more to occur below 30 
> MHz, at the power supply switching frequency, IF the medical device 
> processed extremely low levels of electrical signals and was poorly 
> shielded.  But I believe there are separate immunity requirements which 
> cover this eventuality as well.
> 
Maybe when you  wrote the above you weren't thinking of the previous 
correspondence in this thread about the proximity of the low-energy lamp to a 
bedside radio. 

Yes, I know, this concerned a radio receiver, what I mean to draw your 
attention to is the discussion about the intention and validity of the EMC 
standards – they simply do not cover situations where devices are placed 
close to each other – so they cannot be relied upon to provide compatibility 
in such situations. 
Military EMC standards are more thorough in this respect.

And as I have already said, commercial EMC standards were not written with 
safety issues in mind, and most safety standards have not been written with 
EMC-related issues in mind (see my IEEE 2001 EMC Symposium paper and my 
longer article in ITEM UPDATE 2001 for details).

So I cannot see that there is any 'inherent' margin of safety in the above 
situation, as you claim there "absolutely is".
 

(And may I suggest that anyone who thinks that the statement in all (or most) 
IEC EMC immunity standards: "Products shall not become unsafe as a result of 
these tests." means that that products which pass those immunity tests are 
necessarily free from EMC-related safety problems, needs to think a little 
bit harder about the subject?)

Regards again, Keith Armstrong

> on 1/5/02 12:23 PM, cherryclo...@aol.com at cherryclo...@aol.com wrote:
> 
> >> Dear Cortland 
>> People can't simply say: "ordinary semiconductors won't demodulate RF 
>> levels produced by an unintentional radiator" ­ even the smallest 
>> amount of RF can be demodulated ­ there are no hysteresis or threshold 
>> effects in a PN semiconductor junction or FET that is biased into its 
>> conduction region (at least not until you get below signal levels 
>> equivalent to less than a single electron). 
>> 
>> What I am sure most engineers would really mean to say is: 
>> "ordinary semiconductors exposed to RF levels from an information 
>> technology product which is fully compliant with all relevant EMC 
>> emissions standards and is at 10 metres distance will generally not 
>> demodulate a sufficient level of interference to make an appreciable 
>> difference to most electronic systems." 
>> 
>> Now we have a statement which has some scientific rigor and some 
>> engineering validity to it. 
>> (Although I do worry that in Europe our harmonised EMC standards only test 
>> emissions up to 1GHz, so what does that say about the possible emitted 
>> fields strengths from a PC with a 1.2GHz clock frequency?) 
>> 
>> Let's see if we can put some meat into this discussion with a real-life 
>> example... 
>> 
>> I once tested a blood sample incubator for RF field immunity. The 
>> incubator was used during screening programs (for cancer and other 
>> diseases) and kept about 100 test tubes at 37.1C (normal blood 
>> temperature), while the reagents in the test tubes changed colour. After 
>> 24 hours of incubation medical staff would inspect the test tubes and 
>> write letters to people telling them they were sick, or that they were 
>> clear of the disease. I don't know what temperature tolerance the reagents 
>> had to give an accurate medical diagnosis, so assume ±0.1C. 
>> 
>> On the front panel of the incubator was a display of its temperature, 
>> which was of course 37.1C. We found that field strengths as low as 1V/m 
>> would cause the incubation temperature to range over full scale, from 
>> heaters fully off (in which case the temperature would decline to ambient) 
>> to maximum (in which case the water used to incubate the test tubes would 
>> boil). 
>> We could use the RF test frequency to control the temperature between plus 
>> and minus full scale over the frequency range 80 to 1000MHz at 1V/m (and 
>> did not test beyond 1GHz). 
>> 
>> Most worryingly, the front panel display would only show temporary 
>> variations from its 37.1C when the RF field was turned off or on, and 
>> would continue to show 37.1C even when the water in the incubator was 
>> stone cold or actually boiling. 
>> 
>> Most demodulation effects in bipolar and FET devices approximate to a 
>> square law - for example a 1dB fall in the field strength (keeping 
>> everything else constant) would typically result in a 2dB fall in the 
>> demodulated 'interference' error signal, as John Woodgate has recently 
>> pointed out. 
>> 
>> If we assume that the 1V/m field strength was causing a 60C temperature 
>> error, how low would we need to make the RF field to get down to the 0.1C 
>> accuracy of the front panel display? 
>> 
>> Assuming square-law characteristics for the device doing the demodulation 
>> I calculate a field strength of around 40mV/m or 92dBmicrovolts/metre. 
>> 
>> You will notice that I have been generous to the incubator and assumed 
>> that the 1V/m field just about caused its temperature error to increase by 
>> 60C to boil the water, whereas it could have been overdriving the internal 
>> circuits by a considerable margin and still suffered a 60C error at 
>> 0.1V/m. We didn't test this possibility as our focus was (as in most of 
>> these cases) on quickly modifying the product so it passed the immunity 
>> test - which we did.. 
>> 
>> 92dBmicrovolts/metre is not a very high RF field level for a PC without 
>> any EMC precautions at a distance of 10 metres. 
>> 
>> How many people reading this would be now be quite happy to place even a 
>> fully-compliant PC (compliant at 10 metres distance, that is) right next 
>> to the unmodified incubator? 
>> 
>> If it helps, imagine that it is your young daughter whose blood sample is 
>> in the incubator to discover which drugs she needs to survive. 
>> 
>> Shall we have a vote on how close we would be prepared to place the PC? 
>> Might be interesting. 
>> 
>> Let's not even think about the problems of proximity to cellphones and 
>> other intentional radiators. 
>> 
>> I didn't mention that the incubator was a small model used for mobile 
>> screening, for installation in a truck adapted for medical screening 
>> purposes which travels to various communities and parks there for a few 
>> days while it tests the local people for disease - hardly a very well 
>> controlled electromagnetic environment. 
>> 
>> What does the above imply for similar incubators in countries that do not 
>> have mandatory EMC immunity standards? Or for older incubators in the EU 
>> that have never had to meet the EMC directive? 
>> 
>> (Please don't reply with the old chestnut that "we haven't heard of any 
>> problems so far, so everything must be OK" - people who should have known 
>> better were using that phrase before September 11th. It is just not an 
>> acceptable argument where safety issues are involved, as any expert in 
>> safety law will tell you. Try: "I've been driving past that school at 
>> 40mph for ten years and haven't hit a kid yet, so it must be safe mustn't 
>> it?" as a test of the concept.) 
>> 
>> Regards, Keith Armstrong 
>> 
>> In a message dated 04/01/02 17:54:23 GMT Standard Time, 
>> cortland.richm...@alcatel.com writes: 
>> 
>> >>> Subj:Re: EMC-related safety issues 
>>> Date:04/01/02 17:54:23 GMT Standard Time 
>>> From:    cortland.richm...@alcatel.com (Cortland Richmond) 
>>> To:    cherryclo...@aol.com 
>>> CC:    emc-p...@majordomo.ieee.org 
>>> 
>>> I don't believe this is what people are saying here. What they are saying 
>>> is, ordinary semiconductors won't demodulate RF levels produced by an 
>>> unintentional radiator. Cortland 
>>> (What I write here is mine alone. 
>>> My employer does not 
>>> Concur, agree or else endorse 
>>> These words, their tone, or thought.) 
>>>  
>>>  cherryclo...@aol.com wrote: 
>>> 
>> Does anyone else think that ordinary semiconductors doesn't respond to RF? 
>> I have tested a product which was little more than an LM324 quad op-amp 
>> for RF immunity using IEC 61000-4-3. This op-amp has a slew rate of 
>> 1V/micro-second on a good day with the wind in its favour. It was housed 
>> in an unshielded plastic enclosure. Demodulated noise that exceeded the 
>> (not very tough) product specification were seen all the way up to 500MHz 
>> at a number of spot frequencies that appeared to be due to the natural 
>> resonances of the input and output cables. 
>> 

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